Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT ruled in favor of the assessee on multiple issues. Interest on GST and late filing fees was held to be allowable as a deduction under section 37, following Supreme Court precedent in Mahalakshmi Sugar Mills that interest paid to government for delayed payments cannot be characterized as a penalty. The Tribunal upheld higher depreciation rates of 30% on dumpers and tippers used for transportation in mining operations, finding the assessee had fulfilled necessary conditions for the enhanced rate. Similarly, the ITAT confirmed the CIT(A)'s decision allowing 40% depreciation on certain motor vehicles used for hire. Finally, the Tribunal deleted an addition under section 69C for alleged unexplained expenditure, as it was based solely on an unsigned Excel sheet recovered from a third party without corroborative evidence.
The ITAT ruled in favor of the assessee on multiple issues. Interest on GST and late filing fees was held to be allowable as a deduction under section 37, following Supreme Court precedent in Mahalakshmi Sugar Mills that interest paid to government for delayed payments cannot be characterized as a penalty. The Tribunal upheld higher depreciation rates of 30% on dumpers and tippers used for transportation in mining operations, finding the assessee had fulfilled necessary conditions for the enhanced rate. Similarly, the ITAT confirmed the CIT(A)'s decision allowing 40% depreciation on certain motor vehicles used for hire. Finally, the Tribunal deleted an addition under section 69C for alleged unexplained expenditure, as it was based solely on an unsigned Excel sheet recovered from a third party without corroborative evidence.
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